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y Criminal Case to be a witness against himself" (DE 242, p.5); see also Edwin v. Price, 778 F.2d 668, 669 ( 1 1 th Cir. 1985) (citing Lefkowitz v. Turley, 414 U.S. 70, 77 (1973)). The privilege is accorded liberal construction in favor of the right and extends not only to answers that would support a
sponsive documents is considered testimonial and is protected by the Fifth Amendment. See In re Grand Jury Subpoena, 1 F.3d 87, 93 (2nd Cir. 1993); Rudy-Glanzer v. Glanzer, 232 F.3d 1258, 1263 (9th Cir. 2000Xthe "privilege" against self-incrimination does not depend upon the likelihood, but upon the possibil
668, 669 (11th Cir. 1985)(citing 2 EFTA00592192 Case 9:08-cv-80119-KAM Document 462 Entered on FLSD Docket 02/04/2010 Page 3 of 14 Lefkowitz v. Turley, 414 U.S. 70, 77 (1973)). The privilege is accorded liberal construction in favor of the right it was intended to secure," Hoffman v. United States
chain of evidence having a tendency to Incriminate Epstein and would threaten to invade his privilege against being required to produce or testify. Rudy-Glanzer v. Glanzer, 232 F.3d 1258, 1263 (9"' Cir. 2000). Accordingly, finding the sought after information would result in testimonial disclosures that wou
ered on FLSD Docket 03/04/2010 Page 3 of 10 in future criminal proceedings." Edwin v. Price, 778 F.2d 668, 669 (11th Cir. 1985)(citing Lefkowitz v. Turley, 414 U.S. 70, 77 (1973)). The privilege is accorded "liberal construction in favor of the right it was intended to secure," Hoffman v. United State
e the requests relate solely to Defendant's net worth and are "unrelated to Defendant's inducement of minors to sexual activity,"' ring hollow. See Rudy-Glanzer v. Glanzer, 232 F.3d at 1263 (the "privilege" against self-incrimination does ' See Plaintiffs' Mtn. (D.E. #333), p.7. 7 EFTA00728622 Case 9:08-
Entities connected to both Turley and Rudy-Glanzer

Jeffrey Epstein
PERSON
Jay Lefkowitz
PERSONHubbell
PERSONJane Doe
PERSON
Edwin
PERSONApfelbaum
PERSON
United States
LOCATION
Rudy Giuliani
PERSONJack Goldberger
PERSONGlanzer
PERSON
Kenneth Marra
PERSON
Adam D. Horowitz
PERSONMichael J. Pike
PERSON
Scarlett Johansson
PERSON
Bradley Edwards
PERSONIsidro Manuel Garcia
PERSON
Paul Cassell
PERSONKatherine W. Ezell
PERSONMermelstein & Horowitz
ORGANIZATIONSpencer Kuvin
PERSON